The Government of Ghana has secured a major legal victory after an international arbitral tribunal ruled in its favour in a tax dispute involving oil producer Tullow Ghana Limited.
In a statement issued by the Ministry of Finance on Wednesday, September 30, 2026, the tribunal, constituted under the Rules of Arbitration of the International Chamber of Commerce, dismissed all claims brought by Tullow against the Republic of Ghana concerning the taxation of business interruption insurance proceeds.
The Ministry said the tribunal upheld in full the Ghana Revenue Authority’s tax assessment of US$393,091,993.70 against the company.
According to the statement, the tribunal found that the tax assessment did not breach the Petroleum Agreements governing the operations of the company. It further ruled that the penalty imposed was properly applied, the assessment was not time-barred and that the enforcement actions undertaken by the Ghana Revenue Authority were lawful.
Finance Minister Dr Cassiel Ato Forson described the outcome as a vindication of Ghana’s long-held position that all companies operating in the country, regardless of their size, are subject to the laws of Ghana.
He commended the Office of the Attorney-General, the Ghana Revenue Authority and Ghana’s external legal counsel, Foley Hoag LLP, for their role in defending the interests of the state during the proceedings.
The Ministry noted that the ruling comes at a crucial period when Ghana and its Jubilee partners are seeking to maximize the prospects of the Jubilee and TEN oil fields.
Despite the outcome of the arbitration, government stressed that Tullow remains a key partner and the country’s largest petroleum producer. It noted that the company’s operations in the Jubilee and TEN fields contribute significantly to Ghana’s energy security, domestic gas supply and employment.
The statement disclosed that prior to the tribunal’s award, discussions had been ongoing between government and Tullow aimed at reaching an amicable resolution of outstanding tax matters. These engagements, it said, would continue and would also cover separate proceedings relating to the disallowance of loan interest.
Government indicated that it would work closely with Tullow to implement the award in accordance with Ghanaian law while ensuring the continued operation of the Jubilee and TEN fields.
The Ministry added that Ghana’s legal framework provides the Ghana Revenue Authority with the authority to determine the timing and manner in which assessed tax liabilities are settled. It emphasized that implementation of the award would seek to secure revenues due the Ghanaian people while preserving Tullow’s capacity to continue operating and investing in the country.
The Finance Minister reaffirmed government’s commitment to balancing tax compliance with the need to sustain investments in Ghana’s petroleum sector.
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